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No CCPs in a Haccp Plan - Can This Be Possible?


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Poll: How many CCP's in your HACCP System? (552 member(s) have cast votes)

How many CCP's in your HACCP System?

  1. 0 (Zero) (138 votes [24.95%])

    Percentage of vote: 24.95%

  2. 1-2 (224 votes [40.51%])

    Percentage of vote: 40.51%

  3. 3-4 (115 votes [20.80%])

    Percentage of vote: 20.80%

  4. 5-6 (50 votes [9.04%])

    Percentage of vote: 9.04%

  5. 7-8 (10 votes [1.81%])

    Percentage of vote: 1.81%

  6. 9-10 (6 votes [1.08%])

    Percentage of vote: 1.08%

  7. More than 10 (10 votes [1.81%])

    Percentage of vote: 1.81%

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#51 Jean

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Posted 05 December 2007 - 07:08 AM

Hi!



A very good discussion thread!

From my view point I would say it is possible to have no CCP's provided the pre-requisites are strong including the GMP, which is again based after a thorough HACCP assessment. As long the process of the unit is of low risk or the likely occurrence of the hazards being introduced is also low, this is possible...... but it will be required to do a thorough verifications and validations timely.<BR><BR>However in my opinion regarding, the high risk products or processes, a zero CCP is still doubtful, even though CP are in place too. Even if the hazards are less likely to occur and the severity is high, I would surely introduce at least one CCP rather than having zero CCP.



BR,



J


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#52 okido

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Posted 13 December 2007 - 02:47 PM

HI!

Sure this thread is interesting but the focus is to much on counting CCP’s, SOP, SSOP, PRP and so on.
Is it sensible to judge a food safety management system on the outcome in numbers of the CCP’s etc or the happiness of auditors if at least one CCP is scored?
Counting the outcome of a process is not telling you much, it is much more interesting too now were the variances in the process are and if this variances are recogniced by the process owners. This is were auditors should focus on.

Have a nice day, Okido


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#53 Simon

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Posted 13 December 2007 - 08:14 PM

HI!

Sure this thread is interesting but the focus is to much on counting CCP’s, SOP, SSOP, PRP and so on.
Is it sensible to judge a food safety management system on the outcome in numbers of the CCP’s etc or the happiness of auditors if at least one CCP is scored?
Counting the outcome of a process is not telling you much, it is much more interesting too now were the variances in the process are and if this variances are recogniced by the process owners. This is were auditors should focus on.

Have a nice day, Okido

I absolutely agree with you Okido. :clap:
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#54 Charles.C

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Posted 15 December 2007 - 02:14 PM

Dear Simon,

or the happiness of auditors if at least one CCP is scored


I applaud Okido also but I vote for pragmatism (comes with age perhaps). :whistle:

Could be an interesting poll ?, eg would you always include at least 1 CCP, obviously will be at least 7 Nos but ... ?

Rgds / Charles.C
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#55 GMO

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Posted 25 June 2008 - 12:39 PM

This came up as a new topic on my system so I read some of it because it was all before I joined.

An HR manager once told me about a site manufacturing raw pastry for another factory to use. He said they had 3 or 4 CCPs to 'feel important'! LOL!!!! I said off the top of my head I couldn't think of any. I've had a lot of HACCP plans with 1 or 2 CCPs but I would take a lot of convincing in any process using cooking, cooling and with metal risks that there shouldn't be CCPs covering each of those processes (so in the case of a pork pie, I'd at least expect to see cooking, cooling, metal detection and chilled storage / despatch, others I would say are more debatable.)


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#56 Simon

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Posted 26 June 2008 - 08:17 AM

GMO it's great to see old topics ressurected by and for new members. Things move and change quickly and new ideas come along.

This came up as a new topic on my system so I read some of it because it was all before I joined.

An HR manager once told me about a site manufacturing raw pastry for another factory to use. He said they had 3 or 4 CCPs to 'feel important'! LOL!!!! I said off the top of my head I couldn't think of any. I've had a lot of HACCP plans with 1 or 2 CCPs but I would take a lot of convincing in any process using cooking, cooling and with metal risks that there shouldn't be CCPs covering each of those processes (so in the case of a pork pie, I'd at least expect to see cooking, cooling, metal detection and chilled storage / despatch, others I would say are more debatable.)


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#57 Cathy

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Posted 18 July 2008 - 02:52 PM

I would never venture to judge a product by the number of CCPs in the process. Although - if I had to...I would consider the one with 2 CCPs potentially 'safer'. It would be quite an exercise in orgnaizational skills and paperwork - let alone food safety - to have 12. One must wonder if the meaning of the word 'critical' is too far diluted with that many CCPs and each is therefore taken less seriously.

On another side note - in the U.S. FSIS, as part of USDA has stated in the past that they do not believe a process exists that does not have a reasonably likely food safety hazard -meaning - they expect a CCP for every process.

This can lead to some silly things at times. In a process where, for example - you receive large frozen products and cut them smaller (still frozen), package and ship - the hazaards are quite minimal - and yet - to keep FSIS from questioning your Plan, a CCP is needed.


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#58 GMO

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Posted 21 July 2008 - 02:45 PM

I agree - especially if you are a processor who buys in part processed ingredients and then supplies another site within the same business. You could argue in your example though that there is a metal risk from the cutting?


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#59 Cathy

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Posted 26 July 2008 - 01:08 AM

You coudl consider metal, of course. If equipment is maintained and inspected - I would consider it unlikely though.


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#60 elias.loisos

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Posted 09 January 2009 - 02:05 PM

Best example I could think of would be a local warehouse that does :

No imports (no meat inspections)
No exports

I've visited some smaller warehouses that held about 10,000 palettes of food products and their operations were a simple a unload+load. I highly doubt such a warehouse's HACCP plan would have a CCP.

As far as production lines are concerned i bet you alot of coordinators dream of not having any CCP's ;)


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#61 wijnand1970

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Posted 10 January 2009 - 07:13 PM

Well,

Did 2 HACCP audits this week with no CCP's :biggrin:
Both where chicken-slaughters (mmm do not know the right translation..) who deliver fresh chicken-meat.

So yes.....0 CCP's is very good possible.


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#62 Marco

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Posted 10 January 2009 - 08:41 PM

Looking at the objectives for implementing a Haccp System, is it possible to have zero CCPs in a Haccp Plan.

My answer is yes....but many would disagree with me. My logic is based on deliberately instituting intervention steps at all steps or a particular step of the process.

Feel free to comment.

Charles Chew


Hello Charles,

I would consider having an high number of CCPs as requiring an higher effort in terms of control training, documentation and therefore the higher the number the higher the probability to lose the control.
With this I am not saying that 0 CCP means better control but I would assume that it could be easier to focus attention and efforts on fewer CCPs rather than many.

When I worked in a bakery (I know it's low risk) there were just 2 CCPs for bread and 3 for crumpets.

Now I am working for an import and distribution business that has a chilled storage and they have the temperature control as a CCP and I am thinking about removing it as there is a continuous alarmed temperature control system and also data loggers to control the temperature of the chillers.


What is the thinking on the above?


Regards,
Marco

Edited by Marco, 10 January 2009 - 08:41 PM.

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#63 Charles Chew

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Posted 11 January 2009 - 05:38 AM

Now I am working for an import and distribution business that has a chilled storage and they have the temperature control as a CCP and I am thinking about removing it as there is a continuous alarmed temperature control system and also data loggers to control the temperature of the chillers.


Hi Marco, I seldom participate in the forum anymore but remain interested in browsing through great comments given by so many contributors. The placement of a continuous alarm sounding device should the set temp. range be breached / violated is indeed an example of an "intervention step" that I mentioned in the thread earlier. By way of pursuing specific measurable objective through effective validations supported by verification activity / activities, it is a risk based assessment and base on objective evidences, you may succesfully reduce the risk status from CCP to CP (or OPRP in ISO 22K terms). IMO, I would review the temp. violation limit to one set slightly more critical than before.


Did 2 HACCP audits this week with no CCP's
Both where chicken-slaughters (mmm do not know the right translation..) who deliver fresh chicken-meat.

Hi, It would interesting to know the structure of your audit plan versus on-site verification to determine whether the chicken-slaughter process can be adequately controlled without a HACCP Plan to deliver end-product at the appropriate level of protection within the specific sector of the food chain. If there no HACCP Plan, is the SOP/SSOP Plan sufficiently strong to support the process to achieve the FSO?

However, I remember very well on one occassion at a food safety conference, the speaker also said that there is no HACCP Plan in a chicken-slaughter house as the CCP is at the consumer end of the food chain where final domestic cooking- (CCP) is required before consumption. I think this presents us another interesting case study to talk about.
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#64 Jean

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Posted 12 January 2009 - 09:41 AM

Well,

Did 2 HACCP audits this week with no CCP's
Both where chicken-slaughters (mmm do not know the right translation..) who deliver fresh chicken-meat.

So yes.....0 CCP's is very good possible.




Dear Wijnand & Marco,



I am really excited to see some comments related to my current work review and could not resist asking a few questions for the farms or slaughter houses or distributors. Are you considering the chemical hazards like antibiotics, hormones etc which any cattle or poultry will be subjected to at any stage of the processing? What controls do you have in place to ensure that the limits are within the acceptable range at the Farms / slaughter houses and how are these verified before the cattle / poultry are sent to slaughter houses or before being slaughtered?
I presume Marco has some meat / fish / poultry imports and would like to know what measures are taken from a distributor’s side to ensure they import & supply safe products to their consumers. Is there any possibility for considering this step as a CCP in farms / slaughter or from a distributor’s side? I would greatly appreciate any feedback for those who are involved in this industry.

Kindly excuse me for my ignorance in this industry and would like to get some info as well.

As Charles Chew mentioned, this will be an interesting case study.

Edited by Jean, 12 January 2009 - 09:46 AM.

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#65 wijnand1970

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Posted 12 January 2009 - 06:57 PM

I am really excited to see some comments related to my current work review and could not resist asking a few questions for the farms or slaughter houses or distributors. Are you considering the chemical hazards like antibiotics, hormones etc which any cattle or poultry will be subjected to at any stage of the processing?

Yes they are part of the HACCP study. But in these cases the chickens are comming from "own" farms. Next to that in the Netherlands there will be no risk when the farmer makes use of "the national plan".

What controls do you have in place to ensure that the limits are within the acceptable range at the Farms / slaughter houses and how are these verified before the cattle / poultry are sent to slaughter houses or before being slaughtered?
See above

Off course there is a full HACCP/BRC plan.
What can go wrong:
- temperature to high; grow of pathogenic micro-organism. But this is not an issue. When the temperature is to high there will be
decay/depravation (not knowing exact word). So pathogenic organism will not have the chance to grow.

At slaughter there can be
feacal contamination. This is no CCP but law. Contamination must be lower then 1%. Even if you do not see it contamination can have taken place.

Metal is not an issue here. Products are not delivered to custumors but to factory's. No guaranty has been given and even so not asked.

Keep in mind that the poultry is not foodsafe yet! It must be heated before consuming.

Well that is it for now. More info can be provided.



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#66 Jean

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Posted 13 January 2009 - 07:05 AM


[i]Yes they are part of the HACCP study. But in these cases the chickens are comming from "own" farms. Next to that in the [/i][i]Netherlands[/i][i] there will be no risk when the farmer makes use of "the national plan". [/i]

What controls do you have in place to ensure that the limits are within the acceptable range at the Farms / slaughter houses and how are these verified before the cattle / poultry are sent to slaughter houses or before being slaughtered? 
[i]See above[/i]

[i]Off course there is a full HACCP/BRC plan.
What can go wrong:
- temperature to high; grow of pathogenic micro-organism. But this is not an issue. When the temperature is to high there will be [/i]decay/depravation ([i]not knowing exact word). So pathogenic organism will not have the chance to grow. 

At slaughter there can be feacal contamination. This is no CCP but law. Contamination must be lower then 1%. Even if you do not see it contamination can have taken place.

Metal is not an issue here. Products are not delivered to custumors but to factory's. No guaranty has been given and even so not asked. 

Keep in mind that the poultry is not foodsafe yet! It must be heated before consuming.

Well that is it for now. More info can be provided. Yes they are part of the HACCP study. But in these cases the chickens are comming from "own" farms. Next to that in the [/i][i]Netherlands[/i][i] there will be no risk when the farmer makes use of "the national plan". [/i]

What controls do you have in place to ensure that the limits are within the acceptable range at the Farms / slaughter houses and how are these verified before the cattle / poultry are sent to slaughter houses or before being slaughtered? 
[i]See above[/i]

[i]Off course there is a full HACCP/BRC plan.
What can go wrong:
- temperature to high; grow of pathogenic micro-organism. But this is not an issue. When the temperature is to high there will be [/i]decay/depravation ([i]not knowing exact word). So pathogenic organism will not have the chance to grow. 

At slaughter there can be feacal contamination. This is no CCP but law. Contamination must be lower then 1%. Even if you do not see it contamination can have taken place.

Metal is not an issue here. Products are not delivered to custumors but to factory's. No guaranty has been given and even so not asked. 

Keep in mind that the poultry is not foodsafe yet! It must be heated before consuming.

Well that is it for now. More info can be provided.[/i]






Dear Wijnand,



Thank you for your response. My query was only with regards to the Chemical residues.

Moreover, I agree Microbiological hazards in chickens from farms or slaughter houses can be controlled by validated time & temperature ratio. IMO, physical hazards are not much of a concern from chicken which can be a quality issue.

Edited by Jean, 13 January 2009 - 07:20 AM.

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#67 Jean

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Posted 13 January 2009 - 07:23 AM

My concern is, when the chickens are exported to other countries, they are (certain sample size) subjected to certain testing which includes testing for unacceptable levels of chemicals along with the other pre / post mortem tests. In such a case what is the chemical hazard a CCP in farms & slaughter houses.


Edited by Jean, 13 January 2009 - 07:27 AM.

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#68 Charles Chew

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Posted 18 January 2009 - 08:26 AM

Are you considering the chemical hazards like antibiotics, hormones etc which any cattle or poultry will be subjected to at any stage of the processing? Yes they are part of the HACCP study. But in these cases the chickens are comming from "own" farms. Next to that in the Netherlands there will be no risk when the farmer makes use of "the national plan".


Interesting subject with regards to potential residual impact arising from chemical hazards that may relate to growth, thereupeutic and sub-thereupeutic feeds had the "national plan" been implemented BUT not in a manner complying fully to national standard / plan thereby suggesting a potential health risk?

Could the "dosage of additives including the grow-out period" process be considered a potential CCP even if regulatory inspections were/are carried for compliance registration? I believe data from V & V would scientifically support such a HACCP Plan.
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#69 Charles.C

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Posted 26 January 2009 - 02:09 AM

Dear All,

The original topic has been well analysed within the existing thread however the topic seems to have now concentrated (shifted) to the subject of chicken so I have added a few thoughts. I was not quite sure how many process steps were included within “slaughtering” but I guess the generic plan below will not support the zero CCP case (?).

Chicken not really my area but I suppose one viewpoint on the acceptability of zero CCCPs is how you orientate yr HACCP plan / risk analysis. Although I hv never actually done it myself (it involves more work), I like the style (and examples) promoted ( amongst others) by the NZFA website using Food Safety Objectives (FSOs) since this seems to me to help focus the selection of CCPs (or clarify reasons for their absence). Their generic chicken plan (2000, see below) is getting a bit old now but contains a superb (IMO) discussion on the health related problems in the industry. However the results of their FSO analysis although very honest can be sometimes rather depressing, eg –

Attached File  chicken_processing.jpg   18.79KB   46 downloads

The chicken related health incidents globally seem (sadly) to currently have not changed all that much in last 10 years except via certain specific control programs (particularly Scandinavian) as detailed in another very nice review (2007) which is included below. I found some comments rather surprising (considering that many legally acceptable raw salmonella contamination levels are probably [implicitly]10% +), eg that incidents traced to raw cross-contamination at the kitchen level are rare.

Attached File  chicken___haccp_v2appix_4.pdf   267.12KB   86 downloads
Attached File  chicken_ccfh_wg_june_07_risk_profile_salmonella.pdf   343.76KB   68 downloads

Rgds / Charles.C

PS I noticed this thread has currently had 13,000 + views, Perhaps No.1?, congratulations CharlesChew :thumbup:


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#70 Jean

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Posted 28 January 2009 - 05:56 AM

Dear Charles,



Thank you for uploading a Generic HACCP plan for slaughter houses. I have got an idea of the processes. :rolleyes:


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#71 Charles Chew

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Posted 28 January 2009 - 06:41 AM

PS I noticed this thread has currently had 13,000 + views, Perhaps No.1?, congratulations CharlesChew


Hello Charles C
Its always good to know that members are actively sharing or participating their views. Although, recently the subject of "chicken slaughtering" seems to draw some degree of interest, I believe it remains relevant to the core subject.

I believe it is possible for the hazard risk status of a matured HACCP Plan in a well committed food safety management system to be downgraded and remain equally effective in managing food control risks under a OPRP Plan provided the analytical data of V & V indicate evidences for such reclassification. Admittedly, due to the dynamic nature of food borne issues, not many organizations would be capable of achieving this capability.

Regards
Charles Chew

PS. "Kong Hei Fatt Choi" and a "Happy Lunar New Year" to all chinese members

Edited by Charles Chew, 28 January 2009 - 06:49 AM.

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#72 rita

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Posted 28 January 2009 - 12:54 PM

Dear Charles Chew,



Sorry for my ignorance as I would like to know what is the full form of V & V.


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#73 Charles Chew

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Posted 29 January 2009 - 01:35 AM

Hi Rita,

To determine the effectiveness and performances of established process control measures and the final product output, analytical data from individual/system validation and verification activities (V & V) are extremely important to determine where your food safety system is against where you want it to be.


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#74 Rey

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Posted 09 June 2009 - 01:08 PM

Hello All,

Sorry for the late response...been getting ready for a Food Safety Assessment being conducted by USDA/FSIS personnel beginning tomorrow.

I would agree that the more CCP's in a plan would make that product safer (or at least that would be the thought process), however, I believe by the time our FSA is complete, we are going to come out with 0 CCP's in our plan.

A little back ground: we are a small pork processing facility in the U.S.A. (no names, don't want to spoil the USDA's fun!!) and currently we have at elast 5 CCP's in our HACCP Plans. (fully cooked, not shelf stable; fully cooked, heat and control oven; raw-ground; and raw, not gorund)

As we reassesed our HACCP Plans, we came to the conclusion that our CCP's are what are called "Courtesy CCP's". I other words, they are there simply to provide a check and balances for the inspection personnel.

Last month, we attempted to remove one of the courtesy CCP's only to receive an Non-compliance Record from the inspection personnel. We have been in a constant battle over whether our CCP's are courtesy or legitimate.

With the use of the regulations and the determination to prove that our CCP's are courtesy, we will be removing them from the HACCP Plans upon completion of the FSA.

So, to answer your qeustion, Charles, yes, it is possible to have 0 CCP's in a HACCP Plan. Let me finish by saying that our products are no less safer without the CCP's than if we did have the CCP's.

Again, is it simply a matter of the more CCP's the safer the product?

Thanks,

Rey


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#75 Simon

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Posted 10 June 2009 - 08:03 AM

Hello All,

Sorry for the late response...been getting ready for a Food Safety Assessment being conducted by USDA/FSIS personnel beginning tomorrow.

I would agree that the more CCP's in a plan would make that product safer (or at least that would be the thought process), however, I believe by the time our FSA is complete, we are going to come out with 0 CCP's in our plan.

A little back ground: we are a small pork processing facility in the U.S.A. (no names, don't want to spoil the USDA's fun!!) and currently we have at elast 5 CCP's in our HACCP Plans. (fully cooked, not shelf stable; fully cooked, heat and control oven; raw-ground; and raw, not gorund)

As we reassesed our HACCP Plans, we came to the conclusion that our CCP's are what are called "Courtesy CCP's". I other words, they are there simply to provide a check and balances for the inspection personnel.

Last month, we attempted to remove one of the courtesy CCP's only to receive an Non-compliance Record from the inspection personnel. We have been in a constant battle over whether our CCP's are courtesy or legitimate.

With the use of the regulations and the determination to prove that our CCP's are courtesy, we will be removing them from the HACCP Plans upon completion of the FSA.

So, to answer your qeustion, Charles, yes, it is possible to have 0 CCP's in a HACCP Plan. Let me finish by saying that our products are no less safer without the CCP's than if we did have the CCP's.

Again, is it simply a matter of the more CCP's the safer the product?

Thanks,

Rey

Thanks for your input Rey. Any new or additional thoughts on this topic?

By the way good luck with the Food Safety Assessment - let us know how you get on?

Regards,
Simon
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Best Regards,

Simon Timperley
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